Brooks StanfieldOn Scene Coordinator

Treoil Industries is an approximately 34-acre site located in Whatcom County, Washington. The site is currently reported as not in operation however historically has been used for tall oil processing, as a biodiesel refinery, and other small scale miscellaneous industrial operations. Tall oil is a byproduct of kraft paper pulping processes and is a mixture of mainly acidic compounds found in pine trees. Tall oil is specifically listed in the US Coast Guard Admiral Card's 1995 memo as an oil that is subject to the Federal Oil Pollution Act/Clean Water Act.

Since the 1980s the site has been the focus of numerous environmental inspections and compliance concerns. In 2000 EPA conducted an assessment to determine potential threats of discharge of oil to waters of the United States. EPA's assessment report referenced Washington Department of Ecology's (Ecology) files showing "many years of poor housekeeping" at the site. A penalty had been issued then by Ecology for "the discharge of spilled material to a drainage ditch that eventually leads to the Strait of Georgia."

In 2014, the State received a formal complaint on the site, which was followed up by several inspections by Whatcom County Health Department and Ecology's Hazardous Waste department. Among the numerous concerns reported during the several inspections that followed the complaint were:
- Black oily residue visible under fresh gravel that was recently placed on the entire length of driveways on the property,
- Large quantities of (bio-oil) oily residue released to the surface of the ground outside of the secondary containment structures,
- A large (10’x10’x4’d) pit located outside of the western property fence line heavily impacted by black oily chemicals,
- An oily substance was present in the secondary containment structures floating on at least a foot of water,
- Uncertainty regarding the integrity of tanks, pipes, and secondary containment,
- Numerous containers of chemicals that were being inappropriately stored and/or poorly managed .
- And numerous totes with unknown liquids with no secondary containment and/or inappropriately stored.

The site is approximately 1.8 miles from the shoreline of the Straight of Georgia, a navigable water of the United States. The Lummi Indian Reservation, which also borders the Straight extensively, is 4 miles south of the site. EPA documented the presence of the drainage ditch identified in the Ecology penalty that runs through the site and actively flows west approximately one mile before connecting with a creek that empties directly into the Straight.

In February 2017 EPA received an updated request for assistance from Ecology to evaluate and address potential threats of discharge of oil to waterways of the United States as well as any potential releases of hazardous substances to the environment. On March 6th, EPA received initial reports from a field visit conducted by Ecology, which outlined a deterioration of safety and environmental conditions on the property including but not limited to: hazardous substances that had released from containers, improper storage and labeling of chemical containers, oil being stored within failing secondary containment or no containment at all, and a complete lack of site security.